Issues: (i) Whether the Rs. 16 crore paid as stamp duty for renewal of a 20-year mining lease/licence is revenue expenditure deductible under Section 37(1) of the Income-tax Act, 1961; (ii) Whether the capitalised cost of the renewed mining licence is eligible for depreciation as an intangible asset under Section 32 of the Income-tax Act, 1961.

Issue (i): Whether the Rs. 16 crore paid as stamp duty for renewal of a 20-year mining lease/licence is revenue expenditure deductible under Section 37(1) of the Income-tax Act, 1961.

Analysis: Mining operations required a statutory mining licence conferring a right to win minerals for the renewed term. That right, being transferable and capable of generating mineral stock for the business, constituted a capital asset within Section 2(14). The payment was the substantive consideration for acquisition of that mining right and not merely an expense for execution or registration of an instrument. Applying substance over form, the nomenclature of the payment as stamp duty and its term-based or recurring character did not change its capital character or create an allowable revenue deduction under Section 37(1).

Conclusion: The payment for renewal of the mining lease/licence is capital expenditure and is not deductible as revenue expenditure under Section 37(1). This issue is decided against the assessee.

Issue (ii): Whether the capitalised cost of the renewed mining licence is eligible for depreciation as an intangible asset under Section 32 of the Income-tax Act, 1961.

Analysis: The payment, having been treated as the cost of acquiring the licence to extract minerals, formed the cost of an intangible business asset. A licence falls within the intangible-asset block eligible for depreciation under Section 32 read with Rule 5. Suspension of mining operations did not permit immediate deduction of the entire unamortised amount.

Conclusion: The capitalised payment is eligible for depreciation at the prescribed rate as an intangible asset, but immediate deduction of the entire balance is not allowable. This issue is decided partly in favour of the assessee.

Final Conclusion: The renewal amount is required to be capitalised as the cost of an intangible mining right and recovered through depreciation rather than allowed as a current revenue outgo.

Ratio Decidendi: Consideration for acquiring or renewing a transferable right that confers an enduring business benefit is capital in character, notwithstanding the nomenclature or frequency of payment.

Issues: Whether the appellant was denied a reasonable opportunity of hearing before the Commissioner (Appeals) because hearing notices were not served, and whether that issue was addressed by CESTAT.

Analysis: The alleged non-service of the hearing notices and the contention that CESTAT decided the appeal on merits without addressing that objection were treated as relevant. Time was sought to verify whether a response on this issue had been filed before CESTAT.

Outcome: Listed for further hearing on 18 February 2026.

Issues: (i) Whether the High Court's order granting bail was legally sustainable; (ii) Whether the completed investigation warranted transfer to a special agency; (iii) Whether bail applicants must make full disclosure of material particulars and criminal antecedents.

Issue (i): Whether the High Court's order granting bail was legally sustainable.

Analysis: An appellate challenge to grant of bail is distinct from cancellation based on post-bail misconduct. A bail order may be annulled where it is perverse, legally untenable, based on irrelevant material, or overlooks material considerations including the gravity of accusations, criminal antecedents and societal impact. The bail order relied upon documents whose genuineness formed the subject of the prosecution, despite prima facie material that the purported institution lacked affiliation to conduct a law course and that the marksheet had not been issued by the University. The respondent's suppression of multiple criminal antecedents materially vitiated the exercise of bail discretion.

Conclusion: The bail order was legally unsustainable and was set aside; bail was cancelled in favour of the appellant.

Issue (ii): Whether the completed investigation warranted transfer to a special agency.

Analysis: Transfer of an investigation to an independent or special agency after filing of the chargesheet is an exceptional measure, requiring cogent material showing bias, mala fides, improper investigation, extraneous influence, or a credible need to restore public confidence. The investigation had concluded, cognizance had been taken, and no substantiated material established that the State investigation was tainted or influenced.

Conclusion: Transfer of the investigation to a special agency was declined.

Issue (iii): Whether bail applicants must make full disclosure of material particulars and criminal antecedents.

Analysis: Suppression or selective disclosure of material facts in bail proceedings amounts to abuse of process and undermines informed judicial discretion. Bail applicants must disclose criminal antecedents, earlier and pending bail applications, coercive processes, custody details, procedural status and other material particulars, supported by affidavit. An illustrative, recommendatory disclosure framework was issued to promote transparency and uniformity, with circulation to High Courts and the district judiciary for appropriate consideration.

Conclusion: Full and candid disclosure of material particulars by bail applicants was reaffirmed, and a recommendatory disclosure framework was issued.

Final Conclusion: The invalid grant of bail was annulled, while the request to transfer the concluded investigation was rejected; institutional measures for transparent bail disclosures were directed.

Ratio Decidendi: A superior court may annul a bail order without proof of supervening circumstances where the order is perverse, relies on suspect or irrelevant material, or ignores material considerations such as criminal antecedents and the gravity of the accusations.

Issues: (i) Whether the 106-day delay in filing the appeal should be condoned; (ii) Whether the long-term capital-gains addition could be sustained without factual verification of whether the transferred land was a capital asset under section 2(14) of the Income-tax Act, 1961.

Issue (i): Whether the 106-day delay in filing the appeal should be condoned.

Analysis: The delay was attributable to the assessee's age, lack of technical knowledge of tax law, and bona fide difficulty in obtaining suitable legal assistance. A liberal and justice-oriented approach was considered appropriate where the delay was neither deliberate nor intentional.

Conclusion: The delay of 106 days was condoned.

Issue (ii): Whether the long-term capital-gains addition could be sustained without factual verification of whether the transferred land was a capital asset under section 2(14) of the Income-tax Act, 1961.

Analysis: Determination of the land's status required verification of its exact location, its distance from the relevant municipal or cantonment limits on the date of transfer, the applicable notifications then in force, and the nature and use of the land. The lower authorities had not undertaken this factual inquiry, despite competing material concerning the inclusion of the village in an urban area and the land's agricultural character.

Conclusion: The capital-gains addition was set aside for fresh examination by the Assessing Officer after verification of whether the land constituted a capital asset and after granting adequate opportunity to the assessee.

Final Conclusion: The taxability of the transfer must be reconsidered on a complete factual determination of the land's status at the time of sale.

Ratio Decidendi: Capital-gains liability on transfer of alleged rural agricultural land cannot be sustained without factual verification of the statutory conditions determining whether it is a capital asset.

Issues: Whether the Tribunal's failure to adjudicate the ground challenging recharacterization of the assessee's services as knowledge process outsourcing services constituted a mistake apparent from the record warranting rectification.

Analysis: The unadjudicated ground concerned whether the assessee's IT and ITeS services could be treated as knowledge process outsourcing services. Since the earlier order addressed only the comparability issue, despite the recharacterization ground having been specifically raised, the omission was an inadvertent mistake apparent from the record under Section 254(2) of the Income-tax Act, 1961.

Conclusion: The omission was rectifiable, and the Assessing Officer was directed to examine the recharacterization issue on the documentary evidence and determine whether the assessee falls within the scope of knowledge process outsourcing services.

Issues: Whether a co-operative commercial premises society is entitled to deduction under section 80P(2)(d) on interest earned from fixed deposits and savings accounts maintained with co-operative banks.

Analysis: Section 80P(2)(d) allows deduction of interest or dividend income derived by a co-operative society from investments with another co-operative society. A co-operative bank remains a co-operative society within the statutory definition. Section 80P(4) excludes a co-operative bank from claiming deduction under section 80P, but does not disqualify another co-operative society from claiming deduction on interest received from investments with such bank. The decision concerning deduction under section 80P(2)(a)(i) was inapplicable to a claim under section 80P(2)(d). Where divergent judicial views existed and no jurisdictional decision was shown, the construction favourable to the assessee was adopted.

Conclusion: Interest earned by the assessee from fixed deposits and savings accounts with co-operative banks qualifies for deduction under section 80P(2)(d).

Issues: (i) Whether a writ of mandamus could be issued to direct framing and implementation of a regulatory framework for cryptocurrency exchanges and transactions; (ii) whether a Special Investigation Team or CBI investigation could be ordered on the facts pleaded; (iii) whether the prayer for release of funds and compensation was maintainable in writ jurisdiction despite disputed questions of fact and private law origins.

Issue (i): Whether a writ of mandamus could be issued to direct framing and implementation of a regulatory framework for cryptocurrency exchanges and transactions.

Analysis: Mandamus lies to enforce an existing public duty and not to compel the legislature to enact law or the executive to frame policy in the absence of a statutory duty. The Court found no legislative vacuum requiring such a direction and held that a constitutional court cannot assume the role of the legislature.

Conclusion: The prayer for framing or mandating a cryptocurrency regulatory framework was declined.

Issue (ii): Whether a Special Investigation Team or CBI investigation could be ordered on the facts pleaded.

Analysis: Direction to the CBI or a similar agency is an extraordinary remedy, to be exercised sparingly and only in exceptional circumstances supported by prima facie material. The record disclosed no such exceptional circumstance or sufficient basis warranting such intervention.

Conclusion: The request for constitution of an SIT and for investigation by a special agency was rejected.

Issue (iii): Whether the prayer for release of funds and compensation was maintainable in writ jurisdiction despite disputed questions of fact and private law origins.

Analysis: The claims for compensation and release of funds depended upon prior determination of liability and involved disputed questions of fact requiring evidence and cross-examination. The entities against whom relief was sought were also held not to be State or public functionaries for the purpose of Article 226, and the dispute was treated as one with private law origins, making writ adjudication inappropriate.

Conclusion: The prayers for release of funds and compensation were not entertained in writ jurisdiction.

Final Conclusion: The writ petition was disposed of after declining substantive relief on the principal prayers, while leaving the petitioners free to pursue the monetary claims before an appropriate forum.

Ratio Decidendi: A writ court will not compel legislation or policy-making, will order a CBI-type investigation only in exceptional cases supported by prima facie material, and will decline writ relief where the dispute turns on contested private law issues requiring factual adjudication.

Issues: (i) Whether a direction for constitution of a Special Investigation Team for investigation into the alleged misconduct of the cryptocurrency exchange was warranted. (ii) Whether the Court could issue a writ of mandamus to direct framing of stricter policies or a regulatory regime for cryptocurrency exchanges dealing in virtual digital assets. (iii) Whether the private respondents were amenable to writ jurisdiction for a direction to release the petitioner's invested monies.

Issue (i): Whether a direction for constitution of a Special Investigation Team for investigation into the alleged misconduct of the cryptocurrency exchange was warranted.

Analysis: The power under Article 226 of the Constitution of India to direct investigation by the CBI or a similar agency is extraordinary and is to be exercised sparingly, cautiously, and only in exceptional cases where the material on record discloses a prima facie case requiring such intervention. The record did not disclose any exceptional circumstance, and no FIR had been registered at the petitioner's instance. Alternative remedies were available in accordance with law.

Conclusion: The request for constitution of a Special Investigation Team was rejected.

Issue (ii): Whether the Court could issue a writ of mandamus to direct framing of stricter policies or a regulatory regime for cryptocurrency exchanges dealing in virtual digital assets.

Analysis: A writ of mandamus lies to enforce an existing legal duty, and the Court cannot assume the role of the legislature by compelling enactment of policy or law on a subject. The petitioner's own reliance on existing remedies showed that the matter was not one of a remediless legislative vacuum warranting judicial creation of policy.

Conclusion: No direction for framing of policy or regulation was issued.

Issue (iii): Whether the private respondents were amenable to writ jurisdiction for a direction to release the petitioner's invested monies.

Analysis: The private respondents were not shown to be State within the meaning of Article 12 of the Constitution of India, nor were they found to be discharging public functions. On that basis, they were not amenable to writ jurisdiction for the monetary relief sought.

Conclusion: The monetary claim against the private respondents was not entertained in writ jurisdiction.

Final Conclusion: The writ petition was disposed of without granting the substantive reliefs sought, while leaving the petitioner free to pursue remedies available in law.

Ratio Decidendi: The extraordinary writ jurisdiction cannot be used to compel a policy-making function or to order investigative intervention absent exceptional circumstances and a prima facie basis, and purely private entities not performing public functions are not amenable to writ relief for private monetary claims.

Issues: Whether the writ petition could be entertained in Delhi when the award, the pending challenge under Section 34, and the recovery proceedings all had their substantial connection with Agra, and whether the doctrine of forum conveniens required relegation to the court having the dominant territorial nexus.

Analysis: The territorial reach under Article 226 depends not on any isolated or slender fact, but on whether the pleaded facts form a material, essential, and integral part of the cause of action. Even where some consequence of the impugned action is felt within the forum, the High Court may decline to exercise writ jurisdiction if another forum is more appropriately connected with the lis. The decision-making authority, the underlying arbitral proceedings, the pending Section 34 proceedings, and the recovery steps were all centred at Agra, while the Delhi connection was only incidental. The writ remedy, being discretionary, could not be treated as available merely because a recovery notice was received within Delhi.

Conclusion: The petition was not fit to be entertained in Delhi and the petitioner was required to pursue remedies before the court of competent jurisdiction at Agra.

Issues: Whether failure to consider the conditional nature of the assessee's non-pressing of reopening grounds, despite liberty to raise legal and factual issues in the departmental appeal, constituted a mistake apparent from the record warranting recall of the appellate order.

Analysis: The withdrawal letter placed before the first appellate authority expressly made non-pressing of the reopening grounds subject to relief being granted on the other grounds. Further, while dismissing the assessee's cross-objection and cross-appeal as withdrawn, liberty had been reserved to raise all factual and legal issues in the departmental appeal. The appellate order nevertheless rejected the reopening challenge on the premise of an unconditional non-pressing and did not adjudicate those issues. This omission, coupled with non-consideration of the assessee's submissions before issuing directions, disclosed a mistake apparent from the record amenable to rectification under Section 254(2) of the Income-tax Act, 1961.

Conclusion: The order in the departmental appeal was recalled for de novo adjudication, with the assessee entitled to raise the reserved legal and factual grounds.

Issues: Whether deduction for investment in a new residential property could be denied because income from a tannery building was assessed under the head 'Income from house property'.

Analysis: The assessee owned one self-occupied residential house and a tannery that was let out. Classification of rental income from the tannery under the head 'Income from house property' did not establish that the tannery was a residential house. The relevant requirement concerns ownership of more than one residential house, other than the new asset, and not the head under which income from a commercial building is assessed.

Conclusion: The assessee was entitled to deduction under Section 54F; denial of the deduction was unsustainable.

Issues: Whether interest awarded under Section 28 of the Land Acquisition Act, 1894 on enhanced compensation for compulsorily acquired land is taxable as income from other sources under the Income-tax Act, 1961.

Analysis: The interest awarded under Section 28 is an accretion to the value of the acquired land and forms part of enhanced compensation, unlike interest for delayed payment under Section 34. The amendments concerning taxation of interest on compensation were directed at the timing of taxation of interest income and did not alter the character of Section 28 interest. The adopted reasoning further treated the contrary view as inapplicable in light of the governing Supreme Court position.

Conclusion: Interest received under Section 28 of the Land Acquisition Act, 1894 forms part of enhanced compensation and is not assessable as income from other sources; the issue is decided in favour of the assessee.

Issues: Whether interest awarded under section 28 of the Land Acquisition Act, 1894 on enhanced compensation for compulsory acquisition of agricultural land is taxable as income from other sources after applying the statutory provisions concerning such interest.

Analysis: Interest under section 28 is an accretion to the value of the acquired land and forms an integral part of enhanced compensation, unlike interest for delayed payment under section 34. The statutory amendments governing taxation of interest on compensation address the year of taxability of interest receipts and do not alter the character of section 28 interest as part of enhanced compensation. The governing Supreme Court position supporting this characterisation remained applicable; a contrary High Court view rendered without considering the subsequent Supreme Court affirmation could not displace it.

Conclusion: Interest received under section 28 of the Land Acquisition Act, 1894 forms part of enhanced compensation and is not taxable as income from other sources; it is eligible for the applicable exemption available to the enhanced compensation.

Issues: Whether the writ petition challenging the show cause notice, order-in-original and GST demand should be entertained when the petitioner raised the plea of amalgamation and non-existence of the earlier GST registration for the first time before the writ court, and whether the petitioner should be relegated to the appellate remedy.

Analysis: The dispute concerned reversal of input tax credit for the period July 2017 to March 2018 under Section 16(2) of the Central Goods and Services Tax Act, 2017, read with Section 41 of the Central Goods and Services Tax Act, 2017 and Section 20 of the Integrated Goods and Services Tax Act, 2017. The petitioner's amalgamation-related contention involved disputed facts and had not been urged before the adjudicating authority, where the petitioner had not responded to the show cause notice or appeared for personal hearing. In these circumstances, the writ court found it appropriate to leave the factual controversy to the statutory appellate forum and to permit consideration of delay if an appeal was filed promptly with the requisite deposit.

Outcome: The writ petition was disposed of by relegating the petitioner to the appellate remedy, with liberty to seek condonation of delay before the appellate authority.

Issues: Whether the impugned order imposing penalty for alleged non-fulfilment of export obligation could be sustained when the petitioner complained of non-service of the show cause notice and hearing notices and sought an opportunity of personal hearing.

Analysis: The dispute turned on compliance with principles of natural justice in the adjudication of the alleged export-obligation default. The petitioner asserted that the notices were only uploaded on the website and that no effective opportunity of hearing was granted. The respondents stated that the communications had been sent to the email address available with them, but also indicated readiness to afford a hearing. In that backdrop, the Court found it appropriate to set aside the impugned order and restore the matter for fresh consideration with notice and hearing.

Conclusion: The impugned order was quashed and the matter was remitted to the adjudicating authority to hear the petitioner and receive documents on the specified date, failing which the impugned order would revive.

Ratio Decidendi: An order imposing adverse fiscal consequences cannot be sustained where effective opportunity of hearing is not shown to have been afforded, and the proper course is to set aside the order and remit the matter for fresh adjudication after granting hearing.

Issues: Whether the company appeals were barred by limitation and whether the delay in filing could be condoned by reckoning limitation from the date of uploading of the impugned order and by excluding the time taken to obtain the certified copy.

Analysis: The appeals arose from orders pronounced in open court on 01.08.2025. The statutory period under Section 61(2) of the Insolvency and Bankruptcy Code, 2016 had to be counted from the day after pronouncement. The party seeking exclusion under Section 12 of the Limitation Act, 1963 was required to apply for a certified copy within the limitation period so as to claim exclusion of the time requisite for obtaining it. The record showed that the certified copy was applied for only on 29.09.2025, long after expiry of the initial limitation period, and no reliable material established that the impugned order was first uploaded only on 26.09.2025. The gap between pronouncement and uploading, even if assumed, could not extend the limitation in the absence of a timely application for the certified copy. Section 4 of the Limitation Act, 1963 did not advance the case on these facts.

Conclusion: The delay could not be condoned and the appeals were held to be time-barred.

Ratio Decidendi: In an appeal under Section 61(2) of the Insolvency and Bankruptcy Code, 2016, limitation runs from pronouncement in open court, and exclusion of time for obtaining a certified copy under Section 12 of the Limitation Act, 1963 is unavailable unless the application for the copy is made within the prescribed limitation period.

Issues: Whether the Assessing Officer's ad-hoc disallowance of 20% of "other expenses" under Section 37(1) of the Income-tax Act, 1961 is sustainable in the absence of any specific defect, infirmity, or rejection of books of account where the assessee furnished detailed ledger accounts, party-wise break-up and TDS particulars and maintained audited books under Section 44AB.

Analysis: The legal framework requires the Revenue to point out specific defects in vouchers or demonstrate that particular expenditures are not incurred wholly and exclusively for business purposes before making disallowances. Estimation or rule-of-thumb disallowances are permissible only where accounts are unreliable, incomplete, or books are rejected. On the facts, the assessee produced detailed ledger entries, party-wise details, invoices, proof of payment, and TDS particulars; the books of account were audited under Section 44AB and were not rejected by the Assessing Officer. The Assessing Officer made a blanket 20% disallowance without identifying any specific unverifiable transaction or defect and the Revenue failed to impeach the 477-page ledger or supporting records even after remand.

Conclusion: The ad-hoc disallowance of 20% of the other expenses is unsustainable and is deleted; the Revenue's appeal is dismissed and the Assessing Officer's disallowance is not confirmed in favour of the assessee.

Issues: Whether registration charges incurred by the seller on transfer of immovable property were allowable as a deduction while computing capital gains.

Analysis: The sale deed recorded an agreement that the seller would bear the purchase and registration expenses. The purchasers were identifiable from the registered deed, and the Revenue did not produce contrary evidence or independent verification to disprove the payment or the contractual allocation of such expenses. In the absence of a dispute on the remaining components of capital gains computation, the claimed registration charges were held to be a genuine outgoing incurred by the assessee in connection with the transfer.

Conclusion: The disallowance of registration charges was not justified and the deduction was allowed in favour of the assessee.

Final Conclusion: The appeal succeeded and the addition relating to registration charges was deleted, with the capital gains computation accepted on the assessee's claim for transfer-related expenses.

Ratio Decidendi: Where a transfer deed expressly places the burden of registration or incidental transfer expenses on the seller, and the Revenue fails to rebut the documentary evidence, such expenditure is allowable in computing capital gains.

Issues: (i) Whether delay in filing the appeal should be condoned; (ii) Whether the assessee is entitled to deduction for indexed cost of improvement claimed on sale of immovable property.

Issue (i): Whether the delay of 348 days in filing the appeal should be condoned and the appeal admitted for adjudication.

Analysis: The Tribunal examined the affidavit and reasons for delay, considered whether the delay was bonafide, whether the assessee gained by the delay, and applied justice-oriented principles and precedent guidance to assess whether condonation is warranted.

Conclusion: Delay condoned and appeal admitted.

Issue (ii): Whether the assessee is entitled to deduction for indexed cost of improvement of the property sold, where documentary proof of expenditure is not available but the registered sale agreement describes a constructed triple-storeyed building.

Analysis: The Tribunal considered the absence of detailed documentary evidence of the claimed improvement expenditure, the registered sale agreement's description confirming the existence of constructed residential building, the claimed amounts and their per square foot implication, and the deceased status of the assessee with representation by legal heir. Balancing the lack of documentary proof against the factual indication of construction and in the interest of justice, the Tribunal exercised discretion to allow a portion of the claimed improvement cost.

Conclusion: 80% of the improvement cost claimed by the assessee is to be allowed for computation of indexed cost of improvement; the Assessing Officer is directed to compute revised indexed cost adopting 80% of the claimed improvement amounts and grant the corresponding deduction. The finding of the lower authority on this point is set aside and the grounds of appeal are partly allowed.

Final Conclusion: The appeal is partly allowed by condoning the delay and granting partial relief on the claimed indexed cost of improvement, resulting in a revision of capital gains computation in favour of the assessee to the extent indicated.

Ratio Decidendi: Where documentary proof of claimed improvement expenditure is lacking but the registered sale deed establishes the existence of significant construction and equity demands relief, the Tribunal may grant a reasonable proportionate allowance of claimed improvement cost for computing indexed cost of improvement, subject to recalculation by the assessing authority.

Issues: Whether the impugned assessment order passed without personal hearing and relying solely on notices uploaded on the GST portal, without effective service, should be set aside and remitted for fresh consideration; and whether the bank attachment effected pursuant to that order should be released.

Analysis: The Court examined the record and found that the show cause notice and related communications were uploaded on the GST portal but the petitioner did not receive any personal notice and no opportunity of personal hearing was afforded prior to passing of the impugned assessment order. The respondent conceded that no personal hearing was provided. The Court applied the statutory methods of service under Section 169(1) of the GST Act and observed that while portal upload is a valid mode of service, the issuing officer must, where there is no response from the taxpayer, explore other modes of service prescribed by the statute (including registered post/RPAD) to make service effective and to ensure the taxpayer is given a meaningful opportunity to be heard. The Court noted that merely completing formalities by portal upload and proceeding ex parte leads to ineffective service and multiplicity of litigation. Considering that the disputed tax amount had been recovered, the Court held that remand for fresh consideration with an opportunity for the petitioner to file objections and to be heard was appropriate. The Court further reasoned that because the impugned order was set aside, any attachment of the petitioner's bank account made pursuant to that order could no longer subsist and ought to be released immediately on production of this order.

Conclusion: The impugned order dated 15.09.2025 is set aside and the matter is remanded to the respondent for fresh consideration; the petitioner is granted three weeks to file reply/objections and the respondent shall give 14 days clear notice fixing a date for personal hearing before passing fresh orders; the attachment on the petitioner's bank account is to be released and the bank instructed to de-freeze the account upon production of this order. The decision is in favour of the assessee.